ARTICLE
18 June 2025

Legal Flash – Environmental Focus: New Obligation For SMEs Concerning The The R.E.N.T.R.I. System (National Electronic Register For Waste Traceability)

WL
Withers LLP

Contributor

Trusted advisors to successful people and businesses across the globe with complex legal needs
R.E.N.T.R.I. (Registro Elettronico Nazionale sulla Tracciabilità dei Rifiuti) a system that has been developed to enhance the management and traceability of waste in Italy...
Italy Environment

R.E.N.T.R.I. (Registro Elettronico Nazionale sulla Tracciabilità dei Rifiuti) a system that has been developed to enhance the management and traceability of waste in Italy will come into effect for all Small and Medium-sized Enterprises (SMEs) starting June 15, 2025. 

New Obligations for SMEs

As of June 15, 2025, registration with the R.E.N.T.R.I. becomes mandatory for:

  • Entities/enterprises producing hazardous waste with a workforce of between 10 to 50 employees.
  • Entities/enterprises producing non-hazardous waste derived from industrial or artisanal activities, with a workforce between 10 and 50 employees.

These SMEs must:

  • Register with R.E.N.T.R.I.: Registration is mandatory for all entities involved in the production, transport, or management of waste.
  • Submit waste data: Detailed information on waste types, quantities, and destinations must be submitted to the R.E.N.T.R.I.
  • Periodically update information: Data must be regularly updated in accordance with ongoing waste operations.
  • Retain documentation: All documentation related to waste management must be kept for the period prescribed by law.

Pursuant to Ministerial Decree No. 59/2023, the first deadline for R.E.N.T.R.I. registration applied — with a final date of February 13, 2025 — to the following operators:

  • Waste recovery and disposal facilities.
  • Transporters and intermediaries of waste.
  • Companies with more than 50 employees that produce hazardous waste or non-hazardous waste from industrial, artisanal activities or from waste, water, or gas treatment.

Sanctions for Non-Compliance

Failure to comply with these obligations may result in administrative fines, as provided for by Art. 4 of Legislative Decree No. 116 of 3 September 2020:

Failure to register or irregular registration:

  • €500 to €2,000 for non-hazardous waste.
  • €1,000 to €3,000 for hazardous waste.

Failure to transmit or incomplete transmission of data:

  • €500 to €2,000 for non-hazardous waste.
  • €1,000 to €3,000 for hazardous waste.

Fines may be reduced to one-third if registration occurs within 60 days of the deadline.

No fines apply for material errors or formal breaches that do not affect waste traceability.

In addition to financial penalties, delayed compliance may lead to further consequences, such as:

  • Regulatory violations: Risk of conducting waste management activities in breach of applicable laws.
  • Reputational damage: Potential harm to the company's image and commercial relationships.
  • Increased inspections: Higher likelihood of checks by competent authorities to verify compliance.

Operational Recommendations

Enterprises are advised to:

  • Promptly verify whether they are subject to registration requirements.
  • Prepare the necessary documentation for registration.
  • Complete registration by the mandatory deadlines.
  • Train staff on the new digital system for waste management.

We remain at your disposal to provide expert support and consultancy services, with the goal of ensuring your full compliance with current regulations governing waste management and traceability.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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